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The Height of Safety

Originally published in AUSTRALASIAN MINE SAFETY JOURNAL / Autumn 2016 /

What do you believe are the current limitations with regard to the Australian laws and standards on work at heights?

My clients say that trying to understand a compliance framework  of 29 different documents is complex. The framework includes regulations, codes of practice and Australian standards. There is disjoint between the building regulations and health and safety laws, and those laws don’t work together. We need documents that reflect the needs of system users, workplace controllers (PCBUs) and facility managers, not just documents that are supply driven.

The height safety standards are set to change- what changes can we expect to see?

AS/NZS 1891 is currently under review. The changes that we can expect to see are quite specific in relation to harness design, equipment testing, load ratings, reference of overseas standards and detailed technical changes. Mostly this impacts manufacturers but workplaces need to be across it all. At committee level we’ve spoken about developing documents that are geared towards system users and workers, but this isn’t part of the plan right now.

There are a broad range of fixed ladders and platforms at sites across Australia. What is the best way that sites can regularly review compliance?

The best way to do this is through ongoing inspections and risk based audits of the equipment. Apart from being common sense, it’s the law. Use equipment checklists that capture all of the elements of mandatory and optional standards that apply and do regular condition inspections. Standards change and equipment gets damaged. Get your site audited.

What are the key issues you see at workplaces in regards to work at heights?

The key issue appears to be the implementation of recommendations and control measures. This gets blocked at funding stage, because CFO’s don’t understand the issues. It often stalls here. I see a lot of emphasis on documentation and filing. Of course this is essential, but on its own it doesn’t practically control hazards. A well-written, plain English audit with realistic estimates for capital and operational budgets are effective tools to get projects properly funded and actually moving. When practical steps are taken and controls get installed, workers don’t fall from height. Getting an audit done is the first step to compliance.

“A recent survey identified that 95 per cent of anchor and static lines layouts wouldn’t work, 31 per cent of
anchors weren’t fit for use, and 94 per cent of fixed ladders failed compliance inspections.”

The testing of fall prevention equipment appears to have been a concerning issue for some involved in work at heights. Are there companies out there that are not adequately testing and inspecting?

Their concern is valid and the problem is real. A recent survey identified that 95 per cent of anchor and static lines layouts wouldn’t work, 31 per cent of anchors weren’t fit for use, and 94 per cent of fixed ladders failed compliance inspections. Inadequate testing and inspection always goes back to the systems of the company, inspector competency, understanding systems and documentation of the testing body. There are no licensing requirements in Australia. There isn’t any nationally recognised training or competency code for fall prevention equipment, even though these are life-saving.

An inspection isn’t simply a tick-and-flick visual inspection of the anchors and the fixing – it means checking the rigging layout, checking fall distances at the specific workplace, looking at rescue plans, and knowing the different types of anchors. It’s all about a safe and compliant environment, not just compliant pieces of equipment.

A solution for businesses contractor accreditation is relying on NATA’s third party accreditation scheme for inspection and testing. This means workplaces don’t have to rely solely on their own due diligence to assess their inspector. NATA accreditation is available to anyone who can prove systems and competency. There are already 3400 organizations out there accredited by them. Not all NATA facilities are accredited to inspect anchors, so check the scope of their accreditation on NATA’s website and make sure it includes AS/NZS 5532 for anchors.

What ways can companies ensure that their anchorage points are adequately assessed and tested?

If you’re going to engage a non-licensed or non-accredited inspector, check out their in-house training records specifically for inspectors, equipment checklists, report formats, independence, calibration records, testing equipment, data capture and safe work practises. Ask questions about internal sign off, peer review and how they manage conflict of interest internally. Make sure that they are doing rigging reviews, design reviews, checking access to the system and understand rescue plans. Confirm that they can do all of this consistently and repeatedly. It’s possible to get one small inspection right, but it becomes a challenge when there are multiple sites that are dispersed and you want consistency in reporting. Ask for NATA accreditation from your inspector and auditor.

Have you performed rescues for people at heights? What are the challenges associated with rescue at height?

I’ve written rescue plans and trialled them for our clients. We also run regular rescue simulations and training for our own inspectors and installers since they work at height. Qantas simulated a rescue at an airport following a workshop that I ran for their team on fall prevention. It took half an hour for the fire brigade to arrive and they had the wrong sized ladder. They couldn’t get the manikin down and it proved that you couldn’t rely on triple-zero and the fire brigade to rescue. Rescue is not the fire services business. Suspension trauma (also known as suspension intolerance) can take place within just a few minutes of hanging in a harness, so the challenges are getting them down really quickly. Every situation and every site calls for a different approach and a site-specific rescue plan. If that had been a real person on the building, suspension trauma would have been a real problem.

EWPs and cherry pickers are used widely to eliminate or minimise access. What do you see are the emerging safety issues with operators of this type of equipment?

It’s important that people are properly trained to EWPs. They’re a higher order control than harness and are generally much safer. The equipment is freely available, easy to rent, so

I think it’s important for contractors to verify that people are appropriately trained and they’ve got procedures in place which usually includes a spotter. A person standing in an EWP hasn’t got visibility below so this needs to be managed.

Do you believe that current risk assessment methods used on-site prior to a work at heights job are adequate?

A risk assessment is procedural and relies on human behaviour and depends on people doing the right thing. On its own it has limited effect since you’re relying on human behaviour and people doing the right thing. If paperwork is excessive then people tend to take limited notice. Rio Tinto uses a simple ‘take 5’ whereby workers get together a few times a day and simply talk about the most critical risks. On-site risk assessments often point to harnesses since they’re readily available and cheap. A compliant risk assessment needs to follow the hierarchy of controls, even if that means taking more time establishing the site and getting ready for work.

From your experience do site operators adequately comply during work at heights tasks?

The level of compliance varies significantly from site to site and even within the same organisation or company. Some people do the right thing and others take short cuts.

If you follow the hierarchy of controls and implement the highest possible control (engineered controls like fixed perimeter protection or platforms), then you’ve got control measures that are easy to use and unlikely to be circumvented. When you are relying on low level controls like personal protective equipment, anchors, static lines and industrial rope access, these are susceptible to misuse. Harness is a PPE-based solution which relies on people doing the right thing. Harness-based solutions are not an engineering control. Get your site audited to the hierarchy of controls for heights.

From your experience at sites, are people well-prepared for a rescue event enough to minimise suspension traumas?

Generally not. Queensland Health and Safety recently flagged this as a real concern following a number of falls and subsequent visits to 120 worksites. The rope access industry continues to struggle with this. There are a few companies doing the right thing, but generally – not. As long as we’re relying on people doing the right thing in an unregulated, unlicensed industry with low barriers to entry this will be a problem.

At the moment all you need to work at heights is a harness, rope, a few karabiners and a half- day online training course. That will get you on most sites. An unregulated industry like this places a financial burden and transfers risk to the workplace manager. Voluntary third party accreditation and certification schemes are the friend of the workplace controller.  That may not be in the best interest of the suppliers of the services, but it relieves regulatory burden from business and contributes toward genuinely safer workplaces.